Am I crazy to remove my holding tank

[mlydon]

Thank you John. My point was that you could have several heads running to the same tank, no requirement for each to have its own.....

Im taking this thread off of instant notification 😁

Matt

[Brewgyver]

Originally Posted by mlydon

Thank you John. My point was that you could have several heads running to the same tank, no requirement for each to have its own.....

Im taking this thread off of instant notification 😁

Matt

I don't believe anybody said each toilet had to be connected to it's OWN individual tank. But as a practical matter, that is the only way to do it, especially for manual heads. With the exception of back to back heads, as is the case in many built-for-charter catamarans, I believe I've seen those connecting two toilets to one holding tank.

Of course, some boats have vacu-flush or other central waste systems that may have two or three or more heads connected to a single holding tank.

[Brewgyver]

Originally Posted by mlydon

Brewgyver,

I think you are dead wrong. The 'it' is the vessel. No one may operate a vessel unless it....

Has lights
Is registered or documented
Etc

Your interpretation would imply that each head had to have its OWN holding tank.....

Matt

By the standard rules of grammar, the "it" pronoun refers to latter (immediately preceding) noun (toilet facility), not the former noun (vessel).

My "interpretation" is not an interpretation, just reading what is written in the regulation.

On the same USCG page there's a paragraph pertaining to vessel manufacturers. Boat builders cannot sell or distribute ANY vessel with an installed toilet facility unless it is equipped with an installed and operational MSD.

[john61ct]

Originally Posted by Don C L

if you are in a no discharge zone, you must have a working MSD and it must not be able to discharge. If you have 2, my read on it is that as long as you have one MSD that complies, the other must have the seacock locked or wired shut.

Originally Posted by mlydon

That doesn’t mean that EVERY head must run to a holding tank. Just that you aren’t putting sewage overboard, and have the means to either treat it or store it, to my eye.

One head used in regulated waters, hooked up to a holding tank, the other direct out for use on passages, should be perfectly legal

Originally Posted by dfelsent

To me this says the vessel must be equipped, not each toilet facility. I read that because the phrase “unless it is” uses the singular rather than the plural. If they meant to refer to toilet facilities it would have said “unless they are”.

The above are all exactly correct

______

Originally Posted by Brewgyver

The OP simply described it as



so not a Type I MSD, just a head, plumbed for direct discharge. This configuration is not allowed anywhere in the U.S.

Originally Posted by Brewgyver

it is not legal to have a head without a certified MSD

Originally Posted by Brewgyver

The "it" in the last sentence is the toilet, not the vessel.

If you have more than one toilet, you have more than one "it" and EVERY it MUST be connected to an operable MSD.

All these assertions have now been proven unequivocally **false**

Originally Posted by mitiempo

any flush type marine head needs a holding tank.

Also false

Originally Posted by BigNut

If the head is OPERABLE, it needs to use an MSD which cannot discharge

No, only for one head. The others may simply be disabled.

Originally Posted by Capn Jimbo

The law and regs here in the US are simple: any head that can discharge to the water MUST have a holding tank and the Y valve must be directed to the holding tank, and must be securely locked (not just directed to the tank) in that position.

Originally Posted by Capn Jimbo

the OP has a working head, with a single valved outlet overboard to the sea. This is absolutely, positively illegal
…

To be legal, this working head must be attached to a holding tank


…


Your existing head valved only to overboard - is ILLEGAL.

All these are false.

> The basic intent is that whichever device you use, it must "prevent the overboard discharge". Both holding tanks and the other devices (incinerators, composters, etc) achieve this.

As does locking the discharge, disabling use of that head.

And as long as one is working.

[Sailmonkey]

Originally Posted by Brewgyver

Actually, if you state something as a fact in any document, and sign your name CERTIFYING that it is true, that is CERTIFICATION. Try a dictionary. I think you are confusing 'Certification' with 'Approval.'

mean 'Approved.' When you buy a PFD, it is stamped 'Approved' not 'Certified.'



I would direct your attention to the words "I certify..."

Ok, signing a document “certifying” that you have a compliant MSD, does not “certify” your MSD.

Where the confusion came from was when someone claimed that MSD’s are certified, then cited the stupid Texas thing.

The Texas certification chafes my junk because the revenue from it is dumped into the general fund, nothing specifically earmarked to assist joe boater with complying with the small NDZ that is downstream of several major municipal sewage treatment facilities.

[Brewgyver]

Originally Posted by Sailmonkey

Ok, signing a document “certifying” that you have a compliant MSD, does not “certify” your MSD.

Where the confusion came from was when someone claimed that MSD’s are certified, then cited the stupid Texas thing.

The Texas certification chafes my junk because the revenue from it is dumped into the general fund, nothing specifically earmarked to assist joe boater with complying with the small NDZ that is downstream of several major municipal sewage treatment facilities.

I agree that the funds should go to pump-out facilities.
But personal certification is just that, and should not be confused with official certification, which to be accurate is official certification of approval.

[peghall]

Type I and II MSDs. Type I is the typical macerator/chlorinated treatment. Type II is the on board treatment like Electrosan. I assume the OP’s direct discharge head is a Type I, but in that I may be in error.


Not quite,Mike... The OP's direct discharge toilet would not be a "Type" anything...any toilet that directly discharges raw waste is illegal in all US waters. It has to go through a USCG certified Type I or II (in waters where the discharge of treated waste is legal...iow, NOT a NDZ) a be held aboard for legal disposal ashore


Here's all the legal skinny on Types I, II and III marine sanitation devices:


33 CFR 159.3

Type I marine sanitation device means a device that, under the test conditions described in §§ 159.123 and 159.125, produces an effluent having a fecal coliform bacteria count not greater than 1,000 per 100 milliliters and no visible floating solids.


That would be a LectraSan, ElectroScan or PuraSan and also the Groco Thermopure. Legal only on boats <66'

Type II marine sanitation device means a device that, under the test conditions described in §§ 159.126 and 159.126a, produces an effluent having a fecal coliform bacteria count not greater than 200 per 100 milliliters and suspended solids not greater than 150 milligrams per liter.



USCG certified treatment device for boats 66' and up, but also legal on boats <66'. However, they're so much bigger, more complex and costly that very few owners of boats <66' opt for a Type II.



Note the difference in the level of treatment required by Type I and Type II.

As you noted, a Type III marine sanitation device means a device that is designed to prevent the overboard discharge of treated or untreated sewage or any waste derived from sewage.



Iow, a holding tank or any other installed device that's designed to hold sewage without discharging it. You can dump it, but it's not designed to allow sewage to flow through it. Type III are automatically certified by the CG. Includes Portapotties--both portable and MSD (has fittings to install vent and pumpout lines) versions, composters and anything else in which "human body waste or the waste from toilets (CFR definition of "sewage")" can be held aboard. That doesn't exclude fittings that allow purposeful discharging beyond the "3 mile limit." It does exclude any flow through device. A Type III can be any material...I knew houseboat owners who recycled used CocaCola syrup 55 gal drums and a few whose houseboats were on pontoons who created legal holding tanks using long pieces of 8" PVC pipe capped off at the ends (and people claim that sailors are cheap!). Bladder tanks are legal if they're vented.


I'll be glad to answer any questions that I didn't answer above.


--Peggie

[Mike OReilly]

Thanks Peggie. Appreciate it.

And in a related thread, since everyone is so interested in head issues, be sure to fill in the poll on which head you have.

Head Poll v2.0 - what type do you have? - Page 3 - Cruisers & Sailing Forums

[Brewgyver]

Originally Posted by john61ct

The above are all exactly correct

______



All these assertions have now been proven unequivocally **false**



Also false

No, only for one head. The others may simply be disabled.



All these are false.

> The basic intent is that whichever device you use, it must "prevent the overboard discharge". Both holding tanks and the other devices (incinerators, composters, etc) achieve this.

As does locking the discharge, disabling use of that head.

And as long as one is working.

John, please read Peggie's post, and explain what this "unequivocal" proof consists of?

[john61ct]

Again, anyone in doubt, just pick up the phone and call your nearest CG station, ask for the petty officer in charge of inspections / enforcement and ask:

"I'm looking at buying a boat with two heads.

One has a holding tank, the other is direct discharge.

As long as the DD one is disabled, locked up, and

we only use the MSD-compliant one with the holding tank,

are we OK like that staying in no-discharge areas?"

If clarification needed

"In other words, only one compliant non-discharging head is enough, as long as all the other direct-discharging ones are locked down, disabled while in the NDZ jurisdictions"

[Brewgyver]

Like I said before, take your chances. If you called a dozen different CG stations, you might get a 50/50 split on the answer. I know a guy that got cited for expired flares, even though he also had unexpired flares on hand. He shouldn't have been cited, but still had to deal with it. And let's not forget all the other agencies that enforce these laws.

The language of the regulation itself is clear enough to read, and Peg Hall is probably a better authority than the average Coasty or DFW officer.

[Capn Jimbo]

Originally Posted by john61ct

Also false

No, only for one head. The others may simply be disabled.

All these are false.

> The basic intent is that whichever device you use, it must "prevent the overboard discharge". Both holding tanks and the other devices (incinerators, composters, etc) achieve this.

As does locking the discharge, disabling use of that head.

And as long as one is working.

Originally Posted by Brewgyver

Like I said before, take your chances. If you called a dozen different CG stations, you might get a 50/50 split on the answer. I know a guy that got cited for expired flares, even though he also had unexpired flares on hand. He shouldn't have been cited, but still had to deal with it. And let's not forget all the other agencies that enforce these laws.

The language of the regulation itself is clear enough to read, and Peg Hall is probably a better authority than the average Coasty or DFW officer.

With all due respect I agree with Brewski. I called Miami - a big station - and they were clear that it really is 50/50, especially on the water. He stated "...it all depends on who stops you and how they feel that day". He strongly urged that any working head had better have a holding tank, and added the officer who inspects will ask "What are you going to do if the other head fails"? And what happens when the other head's tank is full?" Most will be sticklers he said, and insist that any working head must be legal, ie able to be discharged inboard (holding tank).

He disagreed that disabling a direct to overboard only head makes it legal, stating "... we have to assume you may use that head and discharge overboard."

You makes your choice and pays your money. You can pay it now, or pay a lot more later. For the OP it's no brainer - he already has an installed tank - adding a Y-valve and a bit of hose is trivial. Why he insists on retaining the ability to dump overboard is hard to understand. Those of us who have compacters only are not so driven.

Carry on.

[senormechanico]

Originally Posted by Capn Jimbo

officer who inspects will ask "What are you going to do if the other head fails"? Most will be sticklers he said, and insist that any working head must be legal, ie able to be discharged inboard (holding tank). He disagreed that disabling makes it legal, stating "... we have to assume you may use that head and discharge overboard."

I would respond, "I guess I'd jump in the water and do the necessary business like any fish would, as it's illegal to discharge sewage from the boat."

That question also begs another question to the brainiac who asks that question. What if only have one head, and it dies in the middle of the sail? Die by explosive internal damage to save the planet?

[john61ct]

Also note that not having **any** head capable of discharging, is a blanket exception from these regs.

Bucket with sawdust and garbage bags for the win 8-)

[Brewgyver]

In some jurisdictions a boat over a certain length MUST have an installed toilet and MSD, think I saw that mentioned in this thread somewhere... IIRC it's over 26 feet? That might not have been USCG, though.

But, yeah, John, I know a couple that have crossed the pacific four times over a period of years on a 27 foot sloop, they use buckets, and have a porta potti for when they're in port.